UK Weekly Sanctions Update - Week of June 3, 2024 | Insights

In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.

1. Russia sanctions

UK court rejects argument that sanctions prevent access to justice in anti-suit injunction case: In Airbus Canada Limited Partnership and JSC Ilyushin Finance Co. (“Ilyushin”), the UK High Court granted a mandatory order and anti-enforcement injunction requiring Ilyushin to discontinue and not enforce Russian proceedings against Airbus Canada because the proceedings breached an agreement to submit disputes to LCIA arbitration. The High Court rejected Ilyushin’s submission that the arbitration agreement should be ignored because the effect of sanctions means that it could nor access justice in LCIA arbitration on the basis that the UK licensing regime enables sanctioned entities to use frozen assets to cover LCIA arbitration costs. (https://www.bailii.org/cgi-bin/format.cgi?doc=/ew/cases/EWHC/Comm/2024/790.html).
Ex-employee claims Amazon breached UK’s Russia sanctions. An ex-employee has alleged that Amazon breached UK sanctions by providing Moscow with its facial recognition technology after Russia’s full-scale invasion of Ukraine. The allegation forms part of evidence presented by Charles Forrest in an unfair dismissal claim brought against his former employer, Amazon Web Services, that is being heard at a London employment tribunal. (Amazon breached UK’s Russia sanctions, claims ex-employee at tribunal (ft.com)).

2. Myanmar sanctions

UK Government amends UK sanctions list under the Myanmar regime: On June 7, 2024, the UK Government amended the entry for the International Gateways Group of Company Limited on the UK sanctions list under the Myanmar regime. This entity remains subject to an asset freeze. (https://assets.publishing.service.gov.uk/media/6662e505716b14967fe341d0/Notice_Myanmar_070624.pdf).

3. Iran sanctions

UK Ambassador to IAEA introduces resolution on Iran’s insufficient cooperation with the IAEA. On June 5, 2024, the UK Ambassador to the IAEA, Corinne Kitsell, introduced a resolution on Iran’s insufficient cooperation with the IAEA on behalf of the E3 (France, Germany and the UK). The resolution responds to Iran’s persistent refusal to cooperate in good faith with the IAEA to clarify outstanding issues relating to undeclared nuclear material detected at multiple locations in Iran (Resolution on Iran’s non-cooperation with the IAEA: E3 statement - GOV.UK (www.gov.uk)).

4. Syria sanctions

UK expands humanitarian exception to Syria petroleum sanctions. On May 24, 2024, the UK introduced the Syria (Sanctions) (EU Exit) Regulations 2024, which amend Regulation 57 of the Syria (Sanctions) (EU Exit) Regulations 2019 inter alia to expand the eligibility criteria for reliance on the humanitarian exception from solely UK-funded companies. (https://www.legislation.gov.uk/uksi/2024/677/contents/made).

5. Other sanctions

UK Government updates strategic export controls licensing data. On June 7, 2024, the UK Government updated its guidance on strategies export controls licensing data, noting that management information release on Israel export licensing, which was initially scheduled for publication on 7 June 2024, will now be published on 11 June 2024. (https://www.gov.uk/guidance/strategic-export-controls-licensing-data#full-publication-update-history).
UK Government updates lists of controlled items on 4 Open General Licences: On 5 June 2024, the Export Control Joint Unit (“ECJU”) amended 4 open general licences (“OGLs”) to update the lists of controlled items following a change to the Export Control Amendment Regulation that came into force on 1 April 2024. The OGLs relate to: (i) dual-use: export after exhibition, (ii) dual-use: chemicals, (iii) dual-use: export after repair/replacement under warranty; and (iv) dual-use: export for repair/replacement under warranty. (https://www.gov.uk/government/publications/notice-to-exporters-202413-updates-to-the-lists-of-controlled-items-on-4-licences/nte-202413-updates-to-the-lists-of-controlled-items-on-4-open-general-licences).